Comments are due November 2 on CMS-3401-IFC, the testing rule. LeadingAge National will be commenting on the following topics and ask you to please share feedback with Jodi Eyigor jeyigor@leadingage.org by Friday, October 23.

• Burden of testing requirements: We’re hearing that the main barriers to testing are the cost of testing, the significant staff time required to complete testing, and access issues including access to rapid turn-around test results. Routine staff testing (based on county positivity rates) seems to be the biggest pain point, with additional concerns around the low threshold for triggering outbreak testing.
• Lack of surveyor testing: LeadingAge sent a letter to CMS on this topic a few weeks ago and plan to include in their comments. They advocate for testing of surveyors, since surveyors are in nursing homes including resident care areas, have close contact with both residents and staff, are observing COVID-19 testing, and live in communities (just like our staff) that may have high positivity rates.
• Burden of reporting requirements: Point-of-care testing requires additional reporting according to CLIA requirements. CDC now allows for this reporting to be done through the NHSN platform; however, each state is responsible for adopting their own reporting process and are not required to utilize the NHSN option.
• Barriers of unnecessary CMPs: LeadingAge has long criticized the use of CMPs. We feel that punishing by taking money away from the provider is detrimental to the quality improvement process.

Questions?

Contact:

Laura Hofmann, MSN, RN – Director of Clinical and Nursing Facility Regulatory Services
c: 425-231-4804